| Comment Number: | OL-10510039 |
| Received: | 3/16/2005 12:26:59 AM |
| Subject: | Notice of Proposed Rulemaking, Request for Comment |
| Title: | National Security Personnel System |
| CFR Citation: | 5 CFR Chapter XCIX and Part 9901 |
| No Attachments |
Comments:
The NSPS is not neutral to the employee who is arbitrarily assigned to a bad project or a poorly managed segment of the organization. The system should not penalize good workers for decisions and actions that are totally out of their hands. The system should be designed to retain and reward those who have demonstrated desired skills, knowledge, and ability to do the work that needs to be done. This means treat everyone in the same organization (having the same commanding officer) equally in terms of reduction in force, consideration for advancement, and pay. The provisions for reduction in pay seem to be to easy to fall back on. In general, many of the provisions of the NSPS make it easy for managers to take all sorts of actions against employees, no matter what the cause of the problem might be. This would give a bad manager excessive power over the employees and the ability to get rid of employees who might be in a position to understand and point out the managers failings. I wouldn't have thought that this might be possible, but I have experienced managers who have lied about their actions knowing full well that it would be their word against other employees. There were other managers who knew that they could successfully exert power over other managers and employees by threatening to spread untrue information that might reflect badly on them. Even relatively senior personel were intimidated because they knew that in a highly competitive promotion environment it doesn't take much to provide a reason to dismiss someone as the best candidate when several people with similar qualifications but without the stain of unsubstantantiated rumors are competing for the same job. The NSPS needs to include inputs from coworkers and others who are not the administrative supervisors. I recieved my worst performance ratings at the same time that my project supervisor and sponsor (customer) were delighted with the job that I was doing. Any personnel system needs to be able to objectively review the contribution of the worker to the product. There are no more knowledgable people than those who are working on the project, those who may have requested assistance from the worker to go beyond the assigned tasks and contribute in ways that were not initially assigned or documented in any formal way. The NSPS also provides the supervisor with great flexibility in changing the expectations for the employee. This type of requirement with limited requirements on the supervisor to talk with the empoyee and discuss and set the new requirements. There are no provisions that the new requirements are reasonable given the circumstances of the tasks and status of the project. This requirement to levy significant changes in expectations for employee performance during the year has no limits to ensure that it doesn't allow continuous changes in direction which could be used to effectively undermine project success and provide a means to easily get rid of workers that the supervisor simply didn't like. Unless there are significant external factors driving changes in project parameters, any significant changes in direction from the supervisor represent failures of the supervisor to effectively plan and anticipate the need to take different approaches to the tasks at hand. The NSPS needs significantly more review and discussion to develop a system that can effectively achieve the goals and level of performance that will be needed in the future. Implementing a system that is not ready for prime time is a mistake that should not be made simply because someone had developed a plan that had an arbitrary date that they would like to meet. Let's get it right. Taking more than 30 days for official review is not an unreasonable requirement if the current product is deficient.